Stéphane Eljarrat

Stéphane is a partner and co-leader of the Investigations & White Collar Defence practice. He is also a member of the Taxation and Litigation practices.

His work in corporate tax dispute resolution includes all aspects of representing clients in disputes with tax authorities, with a focus on income tax and sales tax disputes in domestic and cross-border matters.

As part of his Investigations & White Collar Defence practice, Stéphane has handled a wide range of criminal investigations and trials. He also advises clients in high-stakes government and regulatory body investigations in complex criminal matters, including under the Corruption of Foreign Public Officials Act, Special Economic Measures Act, the Competition Act, the Income Tax Act, the Customs Act, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Security of Information Act. He has extensive expertise in criminal investigations and proceedings, including search and seizures, production orders, general warrants and wiretaps under the Criminal Code.

Stéphane has advised both Canadian and foreign corporate clients on internal investigations, both domestic and international, as well as on the design and implementation of compliance programs.

Before joining Davies as a partner, Stéphane worked for the Department of Justice Canada with the Royal Canadian Mounted Police Legal Services and the Department of Justice Tax Litigation Section and as a federal prosecutor. He also worked for the Department of Legislation and Investigations of the ministère du Revenu of the Province of Québec (now Agence du revenu du Québec) and for the Ministry of Public Safety.

Stéphane acts (or has acted) for publicly listed and privately controlled corporations in Canada, the United States and EU countries. He regularly appears before the Tax Court of Canada, the Federal Court, the Superior Court of Québec, various provincial courts, as well as at appellate levels, including the Supreme Court of Canada. He is also permitted to act before French courts and tribunals (District of the Paris Court of Appeal).

Representative Work

  • Acted for Abitibi-Consolidated in a litigation with the federal tax authorities.

  • Acted for major U.S. and Canadian companies in connection with transfer pricing disputes.

  • Acted for a major public company in connection with criminal charges laid by the Competition Bureau for alleged price-fixing.

  • Acting before the Court of Québec for a major Québec-wide energy provider in a litigious tax matter involving the Québec Revenue Agency. The Québec Revenue Agency reassessed four of the client's taxation years, adding very significant amounts to its stated capital for the purpose of the Québec tax on capital.

  • Acted for a public company in the metals and chemicals sector. Stéphane led an international internal investigation in connection with allegations of wrongdoing against former owners of a company that our client had acquired.

  • Acted for a US-based company active in the North American construction manufacturing sector and having worldwide operations. Stéphane led an internal investigation and advised the client in connection with a tax-related criminal investigation and allegations of corruption.

  • Acted for a Canadian clothing company. Stéphane led an internal investigation following allegations of wrongdoing and violation of customs regulations. This file involved acts committed in the United States, China and Mexico.

  • Acted for a parapublic institution. Stéphane advised the client in connection with a criminal and administrative investigation.

  • Acting for a prominent family holding corporation in a litigious tax matter before the Tax Court of Canada and Federal Court of Appeal. At issue are reassessments by the Canada Revenue Agency (CRA) adding significant amounts to the client's income under section 94.1 of the Income Tax Act, an anti-avoidance provision designed to tax investments in "offshore investment funds" that were made to avoid Canadian tax. This provision was previously considered inapplicable to day-to-day investments by Canadians in large and reputable international funds.

  • Acting for Canadian Forest Navigation, a leading international shipping and navigation company, in its appeals to the Tax Court of Canada and the Federal Court of Appeal against tax reassessments. These appeals deal with the effects of foreign rectification orders as well as with Canadian tax issues applicable to many Canadian international shipping companies.

  • Acting before the Superior Court and the Québec Court of Appeal for a foreign trust in proceedings to declare an administrative act by Revenue Quebec ultra vires.

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  • Recognized in Chambers Canada: Canada’s Leading Lawyers for Business in Litigation: White-Collar Crime & Government Investigations (Band 1).
  • Named White-Collar/Enforcement/Investigations Litigator of the Year by Benchmark Canada.
  • Named a Litigation Star in the areas of Commercial Litigation and White Collar Crime by Benchmark Canada: The Definitive Guide to Canada's Leading Litigation Firms & Attorneys.
  • Recognized as a top legal practitioner in Expert Guides’ Guide to the World’s Leading White Collar Crime Lawyers.
  • Recognized as one of the world's leading tax dispute resolution lawyers in International Tax Review's Tax Controversy Leaders.
  • Recognized in The Best Lawyers in Canada  in the area of Tax law.
  • Recognized as a leading business law practitioner in Who’s Who Legal: Canada—Investigations and Who’s Who Legal: Investigations.

Professional Affiliations

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Member of the Association of Certified Financial Crimes Specialists

Member of the Advisory Committee on Solicitor-Client Privilege of Barreau du Québec

Member of the Legal Committee of Transparency International Canada

Member of the CBA's Anti-Corruption Team (CBA-Act) of Canadian Bar Association (National)

Member of the ABA

Member of Chamber of Commerce France-Canada

Canadian Tax Foundation

Association de planification fiscale et financière

President of Montréal Bar Liaison Committee with the Tax Court of Canada

Past chair of the Tax Section of the Canadian Bar Association (Québec Division) Paris

Board Memberships

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Community Involvement

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Teaching Engagements

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Speaking Engagements

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Stéphane regularly gives presentations on a variety of subjects related to his practice at seminars and conferences organized by Transparency International, the Canadian Corporate Counsel Association, the Tax Executives Institute, the IBA (Business Crime Unit), the Québec Judicial Council, the Québec Bar and the Canadian Bar Association.

On June 2nd, 2016 Stéphane spoke at a Davies Continuing Legal Education session on the subject of: Managing the Challenges of Foreign Anti-Corruption Legislation

On October 27, 2015, Stéphane spoke at the Davies Legal Update, fall 2015 on the subject of: Québec and Canadian regulation of lobbying activities.

He gave a presentation on the subject of the “Anti-Corruption Compliance: Protecting your Company” at the 17th Annual Corporate Governance Conference of the Canadian Society of Corporate Secretaries held in Montréal on August 17, 2015.

Articles and Publications

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Stephane Eljarrat
Stéphane Eljarrat
Montréal, Toronto
514.841.6439 / 416.863.6407
Bar Admissions:

Québec, 1994

Ontario, 2011

Paris, 2012


Université de Montréal, LL.B., 1993